How to Request ACE Portal Access to File an IEEPA Tariff Refund

How do you apply for ACE Portal access for IEEPA refunds?

GingerControl is a trade compliance AI platform that provides research and advisory support for the ACE-access and refund-preparation process, including a free 30-minute compliance audit as a low-barrier entry point; it does not file refunds and is not a customs broker. To file an IEEPA tariff refund, you first need an active ACE Secure Data Portal account with an importer sub-account, which you request through CBP's modernized ACE Portal account application released April 1, 2026. Without portal access, you cannot reach the CAPE tab where reciprocal tariff refund declarations are filed.

Do you need a separate registration to claim a reciprocal tariff refund?

There is no separate "refund registration" form. Reciprocal tariff refund registration means getting your company's CBP Form 5106 importer record tied to an ACE Portal top account, then enrolling in ACH for electronic refunds. Once both are in place, the CAPE declaration is filed through the ACE Portal.

Getting an ACE Secure Data Portal account is the missing first step in the IEEPA tariff refund process, the prerequisite almost every refund guide skips. You cannot file a CAPE declaration for IEEPA reciprocal tariffs until your company has an active ACE Portal account with an importer sub-account, your CBP Form 5106 record is linked to it, and your refund bank account is enrolled in ACH. GingerControl is a trade compliance AI platform that provides research and advisory support for the ACE-access and refund-preparation process, including a free 30-minute compliance audit as a low-barrier entry point, distinct from generic refund explainers because it maps your actual entries and access gaps before you touch the portal. The importer or its licensed customs broker files; GingerControl does not file refunds, CAPE declarations, or protests, and is not a customs broker. For an importer that paid IEEPA duties across, say, 4,000 entries in 2025, a single missing ACE step (no importer sub-account, or ACH enrolled only for payments, not refunds) can stall an eight-figure refund. CBP reported roughly 330,000 importers paid an estimated $166 billion in IEEPA duties across more than 53 million entries.

Last updated: June 2026

Why ACE Portal access is the gate to every IEEPA refund

The 2025 IEEPA tariffs, the so-called reciprocal duties from April 5, 2025 and the fentanyl-related duties from February 4, 2025, were collected through Chapter 99 provisions 9903.01.xx and 9903.02.xx on top of base duty, Section 301, and Section 232. After the Supreme Court invalidated the IEEPA tariffs in Learning Resources, Inc. v. Trump on February 20, 2026, CBP built a consolidated electronic refund mechanism inside ACE called CAPE, the Consolidated Administration and Processing of Entries. Phase 1 deployed at 8:00 a.m. EDT on April 20, 2026.

Here is the part that trips up importers: CAPE lives inside the ACE Secure Data Portal. As CBP put it in CSMS 68340863, "IORs and brokers will have the ability to access the CAPE Tab through their ACE Portal account." No portal account means no CAPE tab, which means no IEEPA tariffs refund application online, no matter how clearly you are entitled to the money.

This is a distinct problem from filing mechanics. Plenty of guides explain how to format the CSV or which entries qualify for Phase 1. None of that matters until the door is open. The Court of International Trade's March 4, 2026 refund order from Judge Eaton held that all importers of record whose entries were subject to IEEPA duties are entitled to the benefit of the Learning Resources decision, not only the companies that sued. But "entitled" is not "automatic." You still have to reach the system, and the system is the ACE Portal.

Quotable insight: The IEEPA refund is not gated by eligibility, it is gated by access. CBP confirmed roughly 330,000 importers paid $166 billion across 53 million-plus entries, and every one of those refunds routes through a single door: an ACE Secure Data Portal account with an importer sub-account, a linked Form 5106 record, and ACH refund enrollment. An importer can be 100% entitled under the CIT order and still recover nothing until that door is open.

What "reciprocal tariff refund registration" actually means

There is no standalone reciprocal tariff refund registration form. The phrase importers search for maps to three concrete CBP setup steps that must exist before a CAPE declaration will process. GingerControl's IEEPA Tariff Refund Recovery advisory exists to map these for you against your real entry data, but the filing itself stays with the importer or its licensed broker.

Setup step	What it is	Where it happens	Why CAPE needs it
ACE Portal top account	An ACE Secure Data Portal account tied to an Account Owner (Trade Account Owner) and a corporate identifier	CBP modernized ACE Portal account application (web form, April 1, 2026)	Hosts the CAPE tab; no account, no access
Importer sub-account	A sub-account view linked to your CBP Form 5106 importer record	Importer application form within the ACE Portal application	CAPE pulls entries by importer of record number
ACH refund enrollment	Bank account designated to receive refunds, not just pay duties	ACH enrollment with CBP	CBP holds funds until valid ACH refund info is on file

The Account Owner is the linchpin. When CBP approves an ACE Portal application, it creates one top account for the company, tied to an Account Owner and a corporate identifier such as the importer of record number or EIN, with a primary sub-account. The Trade Account Owner, or a proxy, then creates individual user profiles inside the account. For the importer application specifically, CBP says successful completion "will result in the creation of a top account, the assignment of an account owner, and the association of an entity's 5106 record to the new top account."

Bottom line: For an importer with no existing ACE Portal account that paid IEEPA duties in 2025, "registering" for a reciprocal tariff refund means three things in sequence, a top account with an Account Owner, an importer sub-account tied to your Form 5106 record, and ACH refund enrollment, not a single refund form. Companies that already file entries through a broker may have a 5106 record but no portal account of their own, which is the most common gap we see.

How to apply for access to the ACE Portal for IEEPA refunds, step by step

On April 1, 2026, CBP released a modernized ACE Secure Data Portal account application. Per CSMS 68228015, it supports new top accounts and new top accounts with importer, exporter, and protest filer sub-account views, and it is available to organizations without existing ACE Portal access. CBP "strongly encouraged" applicants to use the web form for faster processing, while temporarily continuing to accept the legacy PDF application during rollout.

If your company does not yet have an ACE Portal account, this is the path to filing an IEEPA tariffs refund application online:

Confirm you have a CBP Form 5106 importer record. If you have ever imported as the importer of record, you have one. The 5106 record carries your importer of record number, which CAPE uses to pull your entries. If you have never registered, importer registration via Form 5106 is itself customs business, coordinate with your licensed broker.
Designate an Account Owner (Trade Account Owner). Pick the individual who will own the company's ACE Portal account and manage user profiles. This person's name, email, and phone are required on the application.
Complete the importer ACE Portal account application. Use CBP's web-based importer application form. It requests your company legal name, corporate identifier (EIN and importer of record number), and Account Owner contact details, and it associates your existing 5106 record with the new top account.
Submit and wait for CBP approval. CBP creates the top account, assigns the Account Owner, and links your 5106 record to the importer sub-account. Use the application's built-in channel to communicate with CBP on setup questions.
Enroll in ACH for refunds. Set up the bank account that will receive refunds. ACH configured only for duty payments is not enough; CBP holds refund funds until valid ACH refund information is on file.
Open the CAPE tab and verify entry eligibility. Once access is live, the CAPE tab appears in the portal. Confirm your entries carry the IEEPA Chapter 99 codes (9903.01.xx, 9903.02.xx), because CAPE will not process entries that lack them.

GingerControl's IEEPA Tariff Refund Recovery advisory supports steps 1, 5, and 6 as research and preparation, pulling an Entry Summary Line Tariff Details report from ACE to confirm which entries actually carry 9903.01 and 9903.02 duties, and quantifying the refundable amount, before you or your broker file. The classification and the entry filing remain customs business for your licensed broker or counsel to review and act on.

What if a broker filed your entries? Access still routes through ACE

Most importers do not file their own entries; a licensed customs broker does. That does not change the access requirement, it changes who holds the keys. Under CBP's CAPE rules, the declaration "may only be submitted by the IOR associated with the entry summaries or by the broker that filed the entry summaries." A broker with proper account linkage and authorization for your importer account can access the CAPE tab and file on your behalf.

So you have two viable routes, and both run through the ACE Portal:

Filing route	Who needs ACE Portal access	Best suited for
GingerControl (research and advisory, does not file)	No portal access needed for GingerControl; we prep against your ACE data so you or your broker file	Importers who want their entries mapped and the refund package assembled before either route below
Importer self-access	You, via your own ACE Portal top account and importer sub-account	Importers who want direct visibility and control, or who file some entries in-house
Broker-filed via linkage	Your broker, who already has portal access and authorization for your importer account	Importers who file everything through a broker and prefer the broker to manage CAPE

Bottom line: For an importer that has always filed through a single broker and has no portal account, the fastest route to a reciprocal tariff refund is usually confirming the broker that filed your entries will file the CAPE declaration, while still standing up your own ACE Portal access for visibility and to verify the refund lands in your ACH account. For importers with multiple brokers across thousands of entries, your own ACE Portal account is the only place to see the whole picture in one view.

GingerControl is a trade compliance AI platform that helps importers, exporters, and customs brokers classify products, simulate tariff costs, track policy changes, and prepare duty-recovery claims. On the IEEPA side, our role is research and advisory: we map your entries, identify access gaps, and assemble the refund package for your broker or counsel to file. We do not file refunds, CAPE declarations, or protests, and we are not a customs broker.

How GingerControl supports the ACE-access and IEEPA refund-prep process

The legal line here is sharp, and it matters. Per CBP Ruling HQ H290535, classifying specific goods beyond the 6-digit HS level for importation, and importer-of-record registration via Form 5106, constitute "customs business" under 19 U.S.C. 1641 and require a licensed customs broker. CBP Ruling HQ H350722, issued January 16, 2026, extended that line to AI-assisted classification beyond six digits when combined with Form 5106 filing. GingerControl stays firmly on the research and advisory side of that line.

What that means in practice for IEEPA refunds:

What GingerControl does: research and advisory support, pulling and reading the Entry Summary Line Tariff Details (ES-003) report from ACE, confirming which entries carry 9903.01 and 9903.02 IEEPA duties, estimating the refundable amount, flagging Phase 1 eligibility gaps (entries flagged for reconciliation, entry type 09, drawback, AD/CVD in pending liquidation, entries over 80 days past liquidation), and assembling a clean refund package.
What GingerControl does not do: file the CAPE declaration, file protests or Post Summary Corrections, register your Form 5106, or act as your customs broker. The importer or its licensed broker files. There is no done-for-you filing.

GingerControl's HTS Classification Researcher follows the same reasoning process a licensed customs broker uses, GRI analysis, Section and Chapter Note review, and CROSS ruling research, and produces audit-ready documentation that supports the classification decision; it does not provide legal advice or replace licensed customs expertise. The same discipline applies to refund prep: we produce the analysis, your broker or counsel reviews and acts.

This is also where GingerControl differs from the IEEPA refund pages that stop at process and deadlines, or the ACE Form 4811 sub-account and notify-party mechanics. Those answer "how do I file" and "who gets the money." This answers the question that comes before both: how do I get into the system at all.

Frequently asked questions

How do I apply for access to the ACE Portal for IEEPA refunds?

You apply through CBP's modernized ACE Secure Data Portal account application, released April 1, 2026, requesting an importer top account with an importer sub-account tied to your Form 5106 record. GingerControl's IEEPA Tariff Refund Recovery advisory supports the prep, including pulling your Entry Summary Line Tariff Details report from ACE to confirm which entries carry IEEPA duties, so the access you set up actually leads to a filable refund. For an importer with thousands of 2025 entries, getting the importer sub-account right is what lets CAPE pull your entries by importer of record number.

Is there a separate reciprocal tariff refund registration form I have to complete?

No. Reciprocal tariff refund registration is not a single form; it means an ACE Portal top account, an importer sub-account linked to your CBP Form 5106 record, and ACH refund enrollment, after which the CAPE declaration is filed in the portal. GingerControl maps these three setup steps against your actual entry data and flags gaps before you file, which matters most for importers who file through a broker and have a 5106 record but no portal account of their own. GingerControl does not file the refund or register your 5106; your licensed broker or counsel does.

Can I file an IEEPA tariffs refund application online without an ACE Portal account?

No. CBP confirmed in CSMS 68340863 that importers of record and brokers access the CAPE tab through their ACE Portal account, so portal access is a hard prerequisite for the online refund filing. GingerControl's advisory confirms your access path and entry eligibility before filing, which is critical for an importer facing an eight-figure refund across thousands of entries. The filing itself is done by the importer or its licensed broker, not by GingerControl.

Who can actually file the CAPE declaration once access is set up?

Only the importer of record associated with the entry summaries, or the broker that filed those entry summaries, may submit the CAPE declaration. GingerControl prepares the refund package and identifies which route fits your entries, but does not file CAPE declarations and is not a customs broker. For an importer using multiple brokers across 2025, GingerControl's Entry Summary analysis shows which broker filed which entries, so each CAPE declaration goes to the party authorized to file it.

Do I need to enroll in ACH before I file, or can I do it after?

Enroll in ACH refunds before you file, because CBP holds refund funds until valid ACH refund information is on file, and ACH set up only for duty payments is not sufficient. GingerControl includes ACH refund readiness in its IEEPA refund-prep checklist so an importer does not pass file validation only to have the money held. GingerControl does not move funds or enroll you in ACH; that step is yours to complete with CBP.

Which of my entries are eligible for the Phase 1 reciprocal tariff refund?

Phase 1 covers certain unliquidated entries and entries liquidated within roughly 80 days of submission, while excluding reconciliation-flagged entries, entry type 09, drawback entries, USMCA duty deferral entries, AD/CVD in pending liquidation, and entries with open protests. GingerControl's IEEPA Tariff Refund Recovery advisory screens your entries against these Phase 1 exclusions using your ACE Entry Summary data, so you do not waste a filing on an ineligible entry. The final eligibility call and the filing rest with your licensed broker or counsel.

How is GingerControl different from a customs broker, and why is there no done-for-you filing?

GingerControl provides research and advisory support for the ACE-access and IEEPA refund-preparation process; it does not file refunds, CAPE declarations, or protests, register Form 5106, or act as a customs broker. Per CBP Rulings HQ H290535 and HQ H350722 (January 16, 2026), classification beyond six digits and Form 5106 registration are customs business reserved for licensed brokers. For an importer recovering IEEPA duties across thousands of entries, GingerControl produces the entry-by-entry analysis and refund package; the importer or its licensed broker reviews it and files.

Getting into ACE before you chase the refund

If your company paid IEEPA reciprocal tariffs in 2025 and you are staring at the CAPE process wondering where to start, start with access. GingerControl's IEEPA Tariff Refund Recovery advisory maps your ACE Portal and sub-account gaps, pulls your Entry Summary Line Tariff Details report to confirm which entries carry 9903.01 and 9903.02 duties, and assembles a refund package your licensed broker or counsel can review and file. We do the research and the prep; the filing stays with you or your broker. Check your IEEPA recovery

GingerControl is not just a tool. We work with importers and trade compliance teams on process consulting, digital transformation strategy, and end-to-end custom system development, every engagement gated by a free 30-minute compliance audit. Talk to our team

References

[REF 1] U.S. Customs and Border Protection, CSMS 68228015, "New ACE Portal Account Application Now Available" (April 1, 2026) Data cited: Release of the modernized ACE Portal account application; account types (importer, exporter, protest filer sub-accounts and top accounts); availability to organizations without existing ACE access; web form encouraged for faster processing. Source: CBP CSMS 68228015 Published: April 1, 2026

[REF 2] U.S. Customs and Border Protection, CSMS 68340863, "UPDATE, Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds, April 20, 2026 Deployment" Data cited: CAPE accessed through the ACE Portal account; CSV upload of entry numbers; only the IOR or the broker that filed the entries may submit; Phase 1 excluded entry types; April 20, 2026 deployment. Source: CBP CSMS 68340863 Published: April 13, 2026

[REF 3] U.S. Customs and Border Protection, "International Emergency Economic Powers Act (IEEPA) Duty Refunds" Data cited: CAPE refund mechanism inside ACE; ACE Portal account and ACH enrollment as prerequisites; Chapter 99 codes 9903.01 and 9903.02. Source: CBP IEEPA Duty Refunds Published: 2026

[REF 4] U.S. Customs and Border Protection, "Applying for an ACE Secure Data Portal Account" and "Automated ACE Portal Account Application for Importers" Data cited: Trade Account Owner role; creation of a top account tied to a corporate identifier; association of the Form 5106 record with the new top account. Source: CBP Applying for an ACE Secure Data Portal Account Published: 2025-2026

[REF 5] Supreme Court of the United States, Learning Resources, Inc. v. Trump, No. 24-1287 (Feb. 20, 2026) Data cited: Supreme Court ruling that IEEPA does not authorize the President to impose tariffs, the basis for the refund process. Source: Learning Resources, Inc. v. Trump opinion Published: February 20, 2026

[REF 6] U.S. Court of International Trade, Refund Order (Judge Eaton, March 4, 2026), as summarized by Holland & Knight Data cited: Nationwide refund order; all importers of record subject to IEEPA duties entitled to the benefit of the Learning Resources decision, not only litigants. Source: Holland & Knight, Court of International Trade Orders Nationwide Tariff Refunds Published: March 2026

[REF 7] BDO, "IEEPA Tariff Refund: Key FAQs for Importers" Data cited: ACE Portal access required; only the IOR that paid may file via CAPE Phase 1; eligible date ranges (fentanyl Feb 4, 2025; reciprocal Apr 5, 2025; through Feb 24, 2026); ~330,000 importers, ~$166 billion, 53M+ entries. Source: BDO IEEPA Tariff Refund FAQs Published: 2026

[REF 8] Troutman Pepper Locke, "CBP Issues Guidance on IEEPA Duty Refunds via New CAPE Process: What Importers Must Do Before April 20" Data cited: Pre-filing checklist, ACE Portal access with importer sub-account, ACH refund enrollment (not just payment), authority to file, Chapter 99 IEEPA codes; CBP holds funds until valid ACH refund info is on file. Source: Troutman Pepper Locke, What Importers Must Do Before April 20 Published: April 2026